2 7. TABLE 2 11 I. EGBA and responsible gaming The European Gaming and Betting Association ( EGBA ) has always sought to promote consistent and comprehensive standards in relation to responsible gaming in the European online gaming industry. A key objective of the association is to ensure that its members operate and constantly seek to promote cross-border online gaming and betting activities in a highly responsible, secure and safe environment. EGBA members are already committed to stringent legally binding regulations, controls and comprehensive licensing requirements imposed by their EU licensing jurisdictions. In addition, EGBA members have developed and adopted on a voluntary basis a set of ambitious self-imposed standards to: Continue to drive change in the industry ahead of less dynamic legislative developments Enforce a consistent and high level of consumer protection across Europe As a result, in 2007 EGBA members adopted a set of nearly 170 comprehensive standards to cover all aspects of online gaming and betting activities and associated services 1. As part of their membership criteria, EGBA members must comply with all standards. Compliance is verified by a compulsory annual audit carried out by ecogra, a leading independent standards and player protection body, which itself is annually subjected to a comprehensive quality assurance review by the audit firm KPMG in London. II. Objective of benchmark study Responsible gaming is a long-term commitment by the industry. In a fast changing online environment, constant monitoring of the best practices available is essential to allow swift updates and improvements to current business procedures. In preparation of its annual EGBA Standards revision, EGBA wanted to compare its current standards with those of other industry actors and in particular those of the leading gambling monopolies in Europe. As a result, in May 2008 EGBA appointed ecogra to perform a benchmarking study of the main national monopolies against the standards imposed by EGBA on its members. The purpose of the study was twofold: To have a better understanding of where EGBA Standards lie in comparison to other industry practices and to draw the necessary conclusions on current best practices, outstanding challenges and priorities 1 The EGBA Standards are available at 2

3 To provide for the first time an independent, fact and evidenced-based comparative assessment of the tools and standards implemented by both private operators and national monopolies. III. Methodology For the purpose of this study, ecogra was able to compare the EGBA consumer facing Standards against those of 10 of Europe s leading gambling monopolies. These EGBA consumer facing Standards are those usually accessible to the general public and in particular those directly available to consumers. The benchmarking study was primarily conducted on a manual (desk based) investigation and research on the practices implemented by national monopolies. The reporting of the findings was completed on a fact-finding basis and was separated into five different categories, namely where EGBA members: Match the practices implemented by national monopolies; Exceed the practices implemented by national monopolies; Could improve their practices based on the practices implemented by national monopolies. Or where the information inspected on the monopolies side was considered as insufficient or Not applicable. The study was conducted at a point in time (between July and September 2008) and therefore does not take into account changes that may have been affected subsequent to the review period. The selected monopolies cover seven EU countries. They were selected because of the high level of promotion given to their responsible gaming standards. The selected national monopolies were: 1. Française des jeux France 2. Pari Mutuel Urbain- France 3. Svenska spel Sweden 4. AB Trav och Galopp Sweden 5. West lotto Germany 6. Bayern Germany 7. Veikkaus - Finland 8. Danske Spil Denmark 9. De /Toto Netherlands Jogos Santa Casa - Portugal The scope of the study covers the following EGBA consumer facing Standards grouped under 9 main principles: 3

4 1. Promote Responsible Gambling and Betting 2. Know-Your-Customer and Prevent Underage Gambling and Betting 3. Zero Tolerance of Fraudulent and Criminal Behaviour 4. Protect Customer Privacy and Safeguard Information 5. Prompt and Accurate Customer Payments 6. Rigorous Independent Assessment of Product Randomness and Fairness 7. Ethical and Responsible Marketing 8. Commitment to Customer Satisfaction and Support 9. Responsible Practices Underpinned by a Safe, Secure and Reliable Environment IV. General findings The findings of the benchmarking study indicate that the majority (over two thirds) of the EGBA consumer-facing standards (hereafter referred as EGBA practices ) benchmarked match or exceed those of the national gaming monopolies. The results indicate that: 67% of EGBA practices match or exceed those of monopolies; o 43% match those of the monopolies o 24% exceed those of the monopolies 4% could be improved in comparison to the practices implemented by the monopolies; 29% could not be benchmarked against those of the monopolies due to insufficient information available or accessible (21%), or as the practice was not applicable (8%) 1. Practices matching or exceeding monopoly practices 4

5 On average 67% of EGBA practices match or exceed monopoly practices: With 73% of EGBA practices matching or exceeding those of Française des Jeux and Svenska Spel (highest rate) And 63% for De, Bayern and Danske Spil (lowest rate) Monopolies FDJ Svenska Spel PMU West Veikkaus ATG Jogos Santa Casa Danske Spil Bayern De EGBA 39% 49% 36% 54% 53% 39% 34% 41% 53% 36% matching monopolies EGBA 34% 24% 35% 14% 15% 27% 31% 22% 10% 27% exceeding monopolies Total 73% 73% 71% 68% 68% 66% 65% 63% 63% 63% The main areas where EGBA members tend to exceed the practices of the monopolies are: 1) Responsible gaming information and tools EGBA members provide players with a responsible gaming link on the homepage of their web sites to a page dedicated to responsible gaming tools (self-exclusion and cooling off options for players), protection measures (setting limits) and help for problem gaming (self-assessment test, helpline numbers, warnings). In addition, the responsible gaming page clearly indicates the process by which players can gain access to each of the tools and protection measures available. 2) Link to assist problem gamblers The homepages of EGBA member web sites contain a link to an organisation that is qualified to assist problem gamblers. 3) Filtering programs EGBA members provide information in their responsible gaming page on filtering programmes that may be used by parents to protect minors from accessing unauthorised web sites. 4) Dispute resolution mechanisms Dispute resolutions mechanisms are readily accessible on the websites of EGBA members. Moreover, independent third parties are available to ensure independent mediation and timely resolution of complaints. 5

6 5) Annual compliance audit EGBA members are subject to an annual audit by an independent third party to ensure continued compliance and enforcement of the EGBA Standards. 2. Practices subject to potential improvements The findings of the benchmark study show 4% of the total findings were in favour of the monopolies and there is scope in these areas for EGBA practices to be improved. 8% of EGBA practices could be improved compared to those of Bayern (highest rate) Only 1% and 2% of EGBA practices are considered as falling short of PMU and West s practices None of the EGBA practices are falling short of those of Jogos Santa Casa, the Portuguese monopoly (lowest rate) Monopolies Bayern FDJ Veikkaus Danske Spil ATG Svenska Spel De West PMU Jogos Santa Casa Monopolies exceeding EGBA 8% 7% 5% 5% 4% 3% 3% 2% 1% 0% EGBA practices which need to be further investigated for future improvements are mostly: 1) Account history Two of the ten monopolies covered by the study provide players with access to their gaming and betting history for a period of up to one year. EGBA members currently provide players with access to their gaming and betting history for a minimum period of one month. 2) Inactive accounts Three of the ten monopolies covered by the study have implemented a policy to ensure that funds left in inactive accounts are remitted to the player. In cases where EGBA members have in place policies to clear inactive accounts they have to specify in their terms and conditions the policy enforced, but the policies as such are different from one member to another. 6

7 3) ID and age verification Monopolies tend to conduct age and customer verification through unrestricted use and access to data contained in their country s population register. In certain jurisdictions, this level of access to a country s data banks is not made available to EGBA members, who instead use leading third-party verification service providers. 3. Practices which could not be benchmarked due to insufficient information The findings have shown that 21% of EGBA practices could not be benchmarked against those of the monopolies due either to insufficient information being available or in inability to access the relevant data in order to reach a conclusion. 27% and 25% of the EGBA practices could not benchmarked against the practices of Danske Spil and Jogos Santa Casa (highest rates) 13% of EGBA practices could not be benchmarked against the practices of the FDJ (lowest rate) Monopolies Danske Spil Jogos Santa Casa De Svenska Spel ATG West PMU Bayern Veikkaus FDJ Insufficient information 27% 25% 24% 22% 20% 20% 19% 19% 17% 13% The findings were the most revealing in relation to the implementation of anti-money laundering policies where ecogra identified that 72% of the consumer facing EGBA practices could not be benchmarked against those of the monopolies because no reference was made to these type of policies in either the monopolies the terms and conditions, annual reports or codes of conduct. EGBA members have implemented and enforced a number of measures to prevent any transactions connected to money laundering or other criminal activity. These measures include, among others: Appointing a person responsible for implementing and ensuring effectiveness of antimoney laundering systems Training and guiding employees to ensure the prompt identification and reporting of suspicious money laundering activities Reporting suspicious transaction to the relevant national financial investigation unit and international institutions 7

8 4. Inapplicable practices which could not be benchmarked The findings have shown that 8% of EGBA practices were not applicable and could therefore not be benchmarked due to the scope of the monopolies offer. 10% of the EGBA practices could not benchmarked against the practices of 7 monopolies (highest rate) 2% of EGBA practices could not be benchmarked against the practices of Svenska Spel (lowest rate) Monopolies ATG West Bayern Veikkaus De Jogos Santa Casa PMU FDJ Danske Spil Svenska Spel Not applicable 10% 10% 10% 10% 10% 10% 9% 7% 5% 2% 5. EGBA conclusions 1) EGBA challenges and priorities The first objective of the study was to provide EGBA with a detailed understanding of best practices available and implemented by the broader industry to be possibly used as a basis for Standards improvements and updates. In order to reflect ecogra conclusions, EGBA immediately endorsed two key changes to its Standards: Improved access of customers to their account history Customers registered on EGBA members website will be provided with an online access to their account history dating back for a minimum period of 60 days, and offline access dating back for a minimum period of 6 months, including all deposits, withdrawals and wagers; Direct customer alerts before enforcing inactive accounts policies When EGBA members have a policy of clearing inactive customer accounts not only will they have to continue to display clearly the exact policy in their terms and conditions but they will now also have to inform the customer prior to clearing of the account. Such direct information will allow the customer to make contact with the operator and instruct him on what to do with the remaining funds on his account. 8

9 2) Legal and regulatory impact of the findings A second objective for the study was to try and get a clear answer on how European licensed operators such as the EGBA members perform in terms of responsible gaming practices compared to national monopolies, which continue to be perceived by some as naturally providing better protection than private operators. This comparative study provides clear evidence that two thirds of the consumer facing tools and practices put in place by EGBA members offer similar or even better consumer protections than those offered by leading national monopolies in Europe. On that basis, EGBA calls for: A fair and non-discriminatory market access for all EU operators offering protection and guarantees that are similar or better than those required within the various EU Member States. Greater transparency in relation to the guarantees and controls currently offered by national monopolies throughout Europe: 21% of EGBA consumer facing practices, which were expected to be publicly available and the most accessible, could not be benchmarked due to insufficient monopoly information available or accessible. Reformed online gambling regulations across Europe Taking into account those guarantees and controls that are already offered by EU regulated operators, based either on the requirements imposed by their licensing jurisdiction or by their self-imposed codes or voluntary standards Fully adapted to the internet: Several member states do not yet provide or offer satisfactory access to national registers for electronic ID and age verification purposes which are crucial in order to minimise fraud and also ensure that no underage players have access to the gambling websites. In member states where e-verification providers can cross-check data electronically against publicly available information positive match rates are as high as 90% and can be efficiently completed by the operator through direct verifications towards the customer. 9

11 Table 2 Description FDJ PMU Svenska Spel ATG West Bayern Veikkaus Danske Spil De Jogos Santa Casa Responsible gaming warning Advice on responsible gaming Self assessment List of protection measures and how to access Links to sources of help Link to assist problem gamblers No promotions on RG pages Direct comms to include RG message Free games have same links to RG Allow limits to be set Clear communication of self-exclusion procedures Ability to self-exclude via phone or web No credit to customers Access to account history Training for appropriate employees Annual conference to educate Senior employee responsible for RG Multi-lingual sites have same info No Under-18 warning on homepage No under-18 requirement in T & Cs No advertising targeting minors or include minors Registration communicates no underage play 11

12 RG pages include link to filtering software If registration for freeplay required, confirmation of age is included Use where feasible and available similar 3rd party age verification to monopolies Work with leading third party age verification partners to improve coverage and quality Training for employees involved in age verification Appoint dedicated Anti Money Laundering (AML) officer AML policies Training on AML for employees AML policies include procedures on reporting of suspicious transactions Legal disclaimer regarding reporting of suspicious transactions Privacy policy on websites Contents of privacy policy Foreign websites will contain same privacy policy details Ts&Cs that require acceptance for registration will include privacy policy Minimum info for registration Ts&Cs make clear that only customers legally permitted by jurisdiction to play may do so Only one account is allowed Inactive account policy should be included in Ts&Cs Records of cleared inactive accounts and settled in accordance with T&Cs Random Number Generator (RNG) shall be tested at least annually Monthly reviews of payout % Advertising shall not be misleading Advertising will not seek to entice underage to gamble 12

13 Advertising will be within the spirit of responsible gaming No misrepresentation that may damage another business or goodwilll of another person Contact information for complaints is clearly available Customers able to log complaints 24/7 Independent third party available for mediation on disputes Compliance manager appointed for ensuring compliance with EGBA standards Commit to annual review of operations by independent third party Annual audit of financial statements and accounts Display name and registered address Display prominently the licensing jurisdiction Appoint compliance officer to ensure compliance with licensing requirements Prominent display of contractual Ts&Cs Ts&Cs shall include last date published Account identifier required before customer can play On Par or Exceed Not Applicable Information insufficient Less 13

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